Despite the extra bureaucracy, ESFA right to require more data on every apprentice

This week the ESFA announced that, from August, apprenticeship providers would need to report the planned off-the-job hours for all new starts.

With bureaucracy a constant bugbear in FE, it is rare that a new field is added to the Individualised Learner Record (particularly a late change) but this is an attempt to address stinging criticism from the National Audit Office.

In their second report into the apprenticeship reforms, the NAO said in March: “The ESFA does not yet have an effective way of identifying where apprentices are routinely receiving less training than they should” and that “this is an important gap in oversight.”

The chair of the Public Accounts Committee, Meg Hillier, similarly put the boot in, claiming that “it is concerning that the Education and Skills Funding Agency can’t be sure that apprentices are spending enough time on off-the-job training”.

In reality, collecting data on planned hours should not be controversial nor require a significant nudge from the NAO, given that providers should already timetable these hours.

Plus, it has been a requirement for ESFA-funded 16-19 study programmes since 2013. In fact, one wonders why the requirement to collect and return this data was not introduced in May 2017, along with the off-the-job rule.

But, a single figure for total planned hours for a whole apprenticeship tells you little about actually delivery.

Compliance with the rule will continue to need auditors to check providers’ own paperwork and systems – although FE Week’s April Fool story in 2017 about an electronic off-the-job card and counter being given to every apprentice does not now seem so fanciful.

However, this mandatory field for off-the-job planned hours in the ILR is a move in the right direction and will serve two
important purposes.

Firstly, as a field in the ILR scrutinised by funding auditors, it will allow knowledgeable data and funding managers to take greater ownership and responsibility for ensuring the apprenticeship delivery plan is compliant with the off-the-job minimum-hour rule.

Secondly, it will help the ESFA and IfA compare planned hours with funding levels and help establish whether the price has been adjusted for prior learning.

If a provider has all their apprentices funded at the maximum, but with a wide variation in planned hours, this is likely to be challenged.

So it’s an overdue but positive step from the ESFA to collect this information, which should improve compliance with both the off-the-job and prior attainment rules.